Cosmetica Italia: How to Successfully Navigate China's Cosmetics Market in 2025

On October 23, 2024, Cisema’s regulatory specialist Miriam Bandinelli shared valuable insights concerning China’s cosmetics market to industry leaders at Cosmetica Italia.

Her presentation, tailored for Italian cosmetic companies, outlined six crucial themes that should be taken into consideration, when seeking to enter or scale-up in Asia’s largest cosmetics market. This article provides a summary of her presentation.

Cosmetics Export Trends and the Role of “Made in Italy”

Although Italian and other European exporters reported impressive growth in China’s $60bn cosmetic market the past decade, Miriam noted that exports have shown a negative trend for the first time in 2023. But this recent development shouldn’t faze companies interested in the Chinese cosmetics market.

Despite slowing growth rates and increased competition, considerable opportunities remain. In the short-term, Italian companies should adapt to changing market dynamics and partner with knowledgeable local experts in the realm of marketing and regulatory affairs.

Miriam also recommended that companies focus on product categories that are still enjoying strong growth in China, such as skincare, haircare, makeup, and perfumery.

Furthermore, she cited a shift in focus, among Italian exporters, towards Hong Kong as a strategic market, due to a more favorable regulatory environment.

Major Regulatory Updates in China’s Cosmetics Market

The presentation then focused on seven important regulatory updates introduced by Chinese regulators since September 2023. These measures had a considerable impact on Italian and other foreign companies operating in China.

I) Dentifrices
Over the next 18 months, new testing methods and streamlined filing deadlines, especially in December 2024, must be observed for dentifrice products (mentioned later in this article).

II) Cosmetic E-Commerce Operators
From September 1 2023, cosmetic e-commerce operators will be subject to new measures that aim to protect Chinese consumers. These measures not only impact platform operators, but also those who sell cosmetics through self-built websites.

III) Excessive Packaging Restrictions
Enacted on September 1, 2023, this raft of regulations will impose strict limits on the packaging space and costs, capping the latter at 20% of products’ selling price.

IV) Annex 14 Guidance
These guidelines came into effect on September 4, 2023 and they aim to standardize and guide the provision of cosmetic raw material safety information. Cosmetic registrants and notifiers (filers) are strongly encouraged to use these guidelines.

V) New Safety Tests
In July 2024, the NIFDC released a significant regulatory update aimed at standardizing safety evaluation practices, with the aim of ensuring cosmetic products are safe, effective, and reliable throughout their shelf life.

VI) Raw Material History Documentation
China’s NIFDC has developed guidelines to streamline the evaluation of new cosmetic raw materials by leveraging their history of safe use. The primary focus is on the traceability and safety of raw materials.

VII) Medical Devices in Beauty
There has been a noticeable shift in requirements for beauty devices, including radio frequency devices; they’re now expected to be aligned with medical device standards and require NMPA approval by April 1, 2026.

Updates to Good Manufacturing Practice (GMP)

China’s Cosmetics GMP, implemented in mid-2022, continues to shape production standards. The GMP consists of 9 chapters and 67 articles that apply to cosmetic products, both finished and semi-finished. It’s important that foreign companies ensure that compliance is maintained at every stage of production.

Penalties for non-compliance are becoming more common, so maintaining high standards and adhering to regulations are non-negotiable. South Korea’s GP Club Co. Ltd is as a cautionary tale of the risks tied to weak compliance.

Domestic Responsible Agent and Cosmetovigilance

Navigating China’s regulatory framework requires a skilled Domestic Responsible Agent (DRA). Miriam highlighted the critical role of DRAs in ensuring smooth product registration and compliance while avoiding fines and reputational damage.

China’s decision in recent years to implement significant reforms, that include tougher product safety requirements and efficacy claims, making it imperative for foreign companies to seek out an experienced DRA.

Miriam then turned her attention towards cosmetovigilance, emphasizing the need for robust systems to monitor product safety in Chinese cosmetics market. Effective cosmetovigilance not only ensures compliance with mandatory adverse reaction reporting but also helps safeguard brand reputation and build consumer trust.

Food Supplements with Beauty Claims

As beauty and wellness increasingly overlap, Miriam shed light on the regulatory changes for food supplements with beauty claims. This includes the latest advertising guidelines and labeling requirements for China’s $45.5bn food supplements market.

She emphasized the growing demand for food supplements with beauty claims in China, noting the importance of adhering to strict labeling and advertising regulations under the National Food Safety Standards. She highlighted the need for transparent claims backed by scientific evidence and the inclusion of mandatory warnings

Critical Regulatory Deadlines

Towards the end of the presentation, Miriam highlighted three important regulatory deadlines that attendees should take into consideration over the next 18 months:

• December 1, 2024: New toothpaste testing methods come into effect.15 testing methods were incorporated into China’s Cosmetics Safety and Technical Standards (CSTS).
• May 1, 2025:Full Product Safety Assessment Reports (PSAR) become mandatory for new filings.
• April 1, 2026:All radio frequency beauty devices must secure NMPA approval to remain on the market.

A Successful Regulatory Strategy in China’s Cosmetics Market

Miriam’s presentation underscored the importance of being proactive, informed, and adaptable in Asia’s largest cosmetics market. There are still ample of commercial opportunities for Italian companies looking to enter or scale-up.

Success in China’s lucrative and dynamic cosmetics market demands expertise—something Cisema, with an international team of regulatory expers, has honed over 5,000 regulatory projects worldwide over the past two decades.

Ready to enter or expand in the Chinese cosmetics market? Let Cisema’s experienced team guide your regulatory journey and help you seize the opportunities in this thriving market. Contact us today and take the first step toward regulatory success in China.